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8/11/2019 Don Henley v. Duluth Holdings - Don a Henley t-shirts.pdf
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^S
THOMAS
P. JIRGAL (SBN 202637)
MELANIE
J.HOWARD
(SBN
218895)
LOEB LOEBLLP
10100 Santa Monica Blvd., Suite 2200
Los Angeles, CA 90067
Telephone: 310.282.2000
Facsimile:
310.282.2200
Attorneys for
Plaintiff
Don Henley
Don Henley,
UNITED STATES DISTRICT COURT
CENTRAL DISTRICT
Plaintiff,
Duluth Holdings Inc., d/b/a Duluth
Trading Company, W cor .v covpo.-a-fr
Defendant.
^m
io
O
I
I
o
en
OF CALIFORNIA
COMPLAINT FOR:
(a)
Trademark
Infringement in
Violation ofU.S.
Lanham
Act, 15
U.S.C. 1114;
(b )
False
Endorsement and
Unfair
Competition in Violation
of
Lanham Act, 15 U.S.C. 1125;
(c) Violation of California Business &
Professions Code 17200;
(d) Violation
of
California
Statutory
Right
of Publicity, Cal. Civ. Code
3344;
(e) Violation
of
Common Law Right
of
Publicity
DEMAND FOR
JURY TRIAL
Plaintiff
Don
Henley
brings
this Complaint against Duluth Holdings
Inc.
d/b/a
Duluth Trading Company ( Duluth Trading Company ) and alleges
for his
Complaint as follows:
COMPLAINT
n
o
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oeb
oeb
A Limited Liability
Partnership
Including Professional
Corporations
o
PREL IM INARY
1. The Eagles are one of the
Don Henley is one of the band's
most
member of the Eagles, Mr. Henley has
public advocate for artists' rights. Hip
portion of the United States population.
2. Duluth Trading Compan
located
in
Wisconsin
that
markets
and
Duluth is a sophisticated marketer that
television stations, by email, and
through
3. In disregard
of
Mr. Henley
violation
of
registered trademarks that
and
distributed
an adver ti semen t
invokes Mr. Henley's name and his
song title) to sell its apparel. Large
Duluth Trading Company's advertisements
Henley is associated
with
and/or has
is untrue.
4. Duluth Trading Company
Henley's name or registered marks, arid
license. To the contrary, Mr. Henley his
that he objects to any unlicensed use of
property rights for commercial purposes
5. Mr. Henley brings this
violation
of
his rights, and to help en$ure
situated
retailers
discontinue
their
unlawful
financial recovery he obtains from this
^ft
STATEMENT
United States' most successful bands, and
well-known members. In addition to being a
achieved fame as a solo performer and is a
name is instantly recognizable by a large
is a highly successful clothing retailer
sells apparel throughout the United States.
advertises its products on national and local
targeted Internet advertising.
's
rights in his name and likeness, and in
he owns, Duluth Trading Company created
ghout the United States that deliberately
association with the Eagles (via an Eagles hit
rfumbers
of
consumers who receive and see
will unquestionably believe that Mr.
en|dorsed the company and its products, which
never sought to obtain a license to use Mr.
Mr. Henley did not grant the company a
publicly made clear on multiple occasions
his name, trademarks, and
other
intellectual
throu;
aption to address a clear and unwarranted
that the defendant and other similarly
violation of his and others' rights. Any
alction will be
donated
to
charity.
COMPLAINT
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Loeb & Loeb
A LimitedLiabilityPartnership
Including Professional
Corporations
A
JURISDICTION AND VENUE
6. This
action
seeks
injunctive relief,
damages, and other appropriate
relief
arises undr the
laws
of
the
Unied
States,
specifically,
the Lanham Act, 15
U.S.C. 1051, et seq. and California state law
7. This Court has original subject matter
jurisdiction over
this action
under 28
U.S.C.
1331
and 1338.
It
has
supplemental
jurisdiction
of
the
common
and state
law
claims pursuant
to 28
U.S.C.
1367 inthat
those claims
are
related
to
claims
under this Court's original
jurisdiction and form
part of
the
same case or
controversy under Article III
of
the United States Constitution.
8. The
Court
has personal jurisdiction over Duluth
Trading
Company
because DuluthTrading Company has established minimum contacts withthe forum
and
the exercise
of
jurisdiction over
Duluth
Trading Company will not offend
traditional
notions of fair
play
and
substantial
justice.
On information
and
belief,
Duluth Trading Company
has
voluntarily conducted
business and
solicited
customers in this District. On information and
belief,
Duluth
Trading
Company
conducts continuous and systematic business in the state of California and
specifically, this District.
9.
Venue is proper in this
District
under
28
U.S.C.
1391(b)(2) because
a substantial part of the events
giving
ise to
Mr.
Henley's claims
occurred
in
this
District.
PART IES
songwriter, recording artist, performer, and
n this District.
11. On information
and
belief,
Defendant
Duluth
Holdings Inc., doing
business
as
Duluth
Trading Company,
is
a
Wisconsin corporation with
its
principal
place of business in Belleville,
Wisconsin.
On
information
and belief, Duluth
Trading
Company has multiple
store loc ations, enjoys a
national customer base, and
COMPLAINT
10. Plaintiff Don Henley is a
public advocate
who
conducts business
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Loeb &
Loeb
A Limited Liability
Partnership
Including Professional
Corporations
A
is a sophisticated national advertiser
in the state
of
California and, specifica
GEN ERAL
12. Mr. Henley is a
drummer, and singer of the Eagles,
musical groups. Every album that
certified platinum, three albums
have
the
Eagles'
Their Greatest Hits 1971
tim e in the Unite d
States
with sales in
hit single Take It Easy was the
album and on the band's best-selling g:
13. As a member of the Eag
list of hits, including Take It Easy,
California. In the 1980s, he launched
Eagles, during which time he wrote anc
Laundry, Boys of Summer, and
performed concerts around the world,
and advocacy on behalf
of
artists' rig
14.
Giv en th e timeless
nature?
Henley, their appeal continues to
culture and their performances routine
result
of
Mr. Henley's undisputed
solo artist, he enjoys instant name reco:
15. Mr. Henley uses his name
performing artist and is the registered
Henley. U.S. Registration Numbers
Apri l 4, 2000
and
June 20, 2000,
registration certificate for
each of
the
o
who markets its clothing nationally, including
ly,
this
District.
ALLEGAT IONS
musician and a founding member,
which is one of the
most successful
American
Eagles has released since 1972 has
been
sjold in excess of
ten million
copies
each,
and
1975 album is the best-selling album
of
all
excess of 29
million
units. The
band's first
lead track on the Eagles' self-titled debut
ileatest hits
album.
, Mr. Henley wrote or performed on a long
'Witchy Woman, Desperado, and Hotel
a successful solo career independent of the
performed a number
of
hits including Dirty
Slunset Grill. During this time, Mr. Henley
;ind became well known for his philanthropy
htt.
of the many hits by the Eagles and Mr.
enduife.
In fact, they
remain
a partof today's pop
y draw large audiences of loyal fans. As a
sucdess as both a member
of
the Eagles and as a
nit ion.
to distinguish his services as a recording and
owner
o f
two tra dema rk s in th e n ame
Don
2337742 and 2359466 were registered on
respectively. A true and correct copy
of
the
se marks is
a tta ch ed a s
Exhib i t A
These
professional
ks,
ir
COMPLAINT
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oeb
oeb
A LimitedLiabilityPartnership
Including Professional
Corporations
f}
o
registrations were duly and legally
and
constitute
conclusive evidence
o
registration of each mark, Mr,
Henley's exclusive right to use the reg
the goods
and
services l is ted in each re
1057(b). Duluth Trading Company
in his federally registered trademarks.
16. On information and
Trading Company distributed an
directed
to
residents of thi s Dis tr ic t
invoked Don Henley Mr. Henley
Henley style shirts. Specifically, as
Henley and the popularity the Eagles'
Company distributed an email to
customers to Don a
Henley
and Tak
online
version of
th e
Advertisement is
issued.
are valid, subsisting, and incontestable,
the validity of each registered mark, the
s ownership
of
each mark, and
of
Mr.
jstered mark in commerce in
connection
with
gistration certificate.
15
U.S.C. 1115(b),
constructive notice ofMr. Henley's rights
5 U.S.C 1072.
', on or about October 6, 2014, Duluth
in interstate commerce that
was
(the Advertisement ). The Advertisement
s
trademarked
namein
an
effort to sell
a means of exploiting the celebrity of Mr.
hit record, Take It Easy, Duluth Trading
nationwide customer base encouraging
It Easy. A true and correct copy of an
attached as
Exhibit
B.
Henley
had
belief,
advertisement
i ts
COMPLAINT
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Loeb &
Loeb
ALimitedLiability Partnership
Including
Professional
Corporations
Q
o
17. At no
time
has Duluti Trading
Company
obtained a license,
authorization, or other permission
to
exploit Mr.
Henley's
name or registered
trademarks in the
manner
described heiein
or
to
capitalize
on Mr. Henley's celebrity
and
status
as
a
famous
musician for
th;
purpose of
driving sales
of
Duluth
Trading
Company's clothing.
On
information
and
belief, Duluth Trading
Company
knowingly distributed the Advertiseme it to its customers with the knowledge
that
it
lacked a
license
to use Mr. Henley's
likeness and registered trademarks
for its
commercial purposes.
FIRST CLAtM FOR RELIEF
(Trademark Infringement inViolation of Lanham Act, 15 U.S.C. 1114)
18. Mr. Henley incorporates b;
r
reference Paragraphs 1through 17
above
as
though fully set forth herein.
19. On information and belie E
Duluth Trading
Company
has
advertised
and sold goods as a result of the Adverisement. This unauthorized use in interstate
commerce is
the
unlawful use of a re
imitation of Mr. Henley's federally
production, counterfeit, copy, or colorable
registered marks and is likely to cause
confusion, mistake,
or to
deceive
the
consuming public
and
trade
by creating the
erroneous impression
that
Duluth
Trading
Company's
product has been
manufactured,
approved, sponsored, endorsed,
or
guaranteed
by, or is in some way
affiliated with Mr. Henley.
has infringed Mr. Henley's trademarks and
1114.
20. Duluth Trading Company
has and continues to violate 15U.S.C.
21.
Due
to
Duluth Trading
Ccmpany's unauthorized
use
of Mr. Henley's
trademarked name, Mr. Henley has and
22. On information and belief,
continues to be intentional, willful, and
Henley's rights.
will
continueto suffer damages.
Duluth Trading Company's conduct has and
with full knowledge
of
the violation
of
Mr.
COMPLAINT
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Loeb & Loeb
ALimited
Liability
Partnership
IncludingProfessional
Corporations
o
23. Duluth Trading
Company
will continue to cause serious and i
proven business success associated
which
hehasno
adequate remedy
at
24. On information and belielf,
will profit by itswrongful conduct and
25. Mr. Henley is entitled to
damages, including attorneys'
fees,
he
profits, and
advantages obtained
by
infringement as alleged above. At
profits, andadvantages
cannot
fully be
i f t
is causing and, unless enjoined
by
the Court,
irreparable
harm to
the
goodwill, reputation,
and
Mr. Henley's registered trademarks for
ith
SECOND
CLAIM
(False Endorsement, Unfair
26. Mr. Henley incorporates b
though fully set forth herein.
27. Mr. Henley is a world fambus
g reat success a s both
a
member of th e
success, he benefit s from instant name
Easy is famously associated with Mr
andpersona in the mindof the public.
28.
Duluth Trading Company
trademarked name in conjunction
successful single, Take It Easy, was
to increase sales of Duluth Trading
Trading Company's other interests.
29. This unauthorized use
and misleading representations
of
fact
cause confusion, or to cause mistake,
law,
Duluth
Trading Company
has profited or
activities.
recover from Duluth Trading Company the
las sustained andwill sustain, andany gains,
Duluth Trading Company as a result of its
p-esent, the amount of such damages, gains,
iscertained by Mr. Henley.
FO R REL IEF
Competition, 15U.S.C. 1125(a))
y reference Paragraphs 1 through25 above as
musician whohas and
continues
to enjoy
Eagles and as a solo performer. Given his
recognition. Further, the hit song Take It
Henley
and
immediately suggests
his
identity
's advertised use of
Mr.
Henley's
the title of the Eagles'
debut, highly
interstate commerce
and
done specifically
Company's clothing and advance Duluth
with
in
constitutes
a false designation of origin and false
Duluth Trading Company that is likely to
to deceive as to the affiliation, connection,
ty
or
COMPLAINT
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Loeb & Loeb
A LimitedLiability Partnership
Including
Professional
Corporations
o
or association of Duluth Trading
origin, sponsorship, or approval of
commercial activities by Mr. Henley,
1125(a).
30. Duluth Trading Comparjy
unauthorized use of Mr. Henley's
the Eagles' hit single, Take It Easy,
the public regarding whether Mr.
associated with, or approved the
31. Due to Duluth Trading
trademarked name,Mr. Henleyhas and
32. On
information and belief
by its wrongful conduct and activities.
33. On information and belief,
continues to be intentional, willful, and
Henley's rights.
34. Duluth Trading Company
will continue to cause Mr. Henley
remedy at law.
35. Mr. Henley is entitled to
15U.S.C. 1117 and prejudgment
o
Coripany and/or with Mr. Henley, or as to the
Dijluth Trading Company's
goods, services,
or
in
violation
of the
Lanham Act,
15
U.S.C.
knew
or should have
known
that its
trademarked
name
in conjunction with the title of
was likely
to
cause confusion
or
mistake
by
Herley endorsed, is affiliated, connected to, or
Adven isement.
Company's
unauthorized use
ofMr.
Henley's
will continue to sufferdamages.
Duluth
Trading Company
has orwillprofit
Duluth Trading Company's conduct has and
with full knowledge of the violation
of
Mr.
s causing and, unless enjoined by the Court,
irreparable harm
for
which
he has no
adequate
his
attorneys' fees and full costs pursuant to
interest according to law.
THIRD
C LA
(Violation
of
California Busihess
36. Mr. Henley incorporates b)
though fully set forth herein.
37. As discussed above, Duluth
cause confusion or mistake regarding
connected to or associated with, or
M FOR
REL IEF
& Professions Code 17200)
referenceParagraphs 1 through 35 aboveas
Trading Company's conduct is likely to
whether Mr. Henley endorsed, is affiliated,
approved the message and content
of
the
COMPLAINT
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Loeb & Loeb
A LimitedLiabilityPartnership
Including Professional
Corporations
Advertisement.
The conduct
of
Duluti Trading
Company is
intended to and likely
has produced substantial benefits to Duluth Trading Company
at
the expense
ofMr.
Henley.
38. Duluth Trading Company's conduct is likely to deceive
the
general
public and constitutes willful and
intentional
unlawful, unfair and fraudulent
business practices, in violation of California Business
&
Professions Code
17200
ts q
39. As a direct and proximate result of Duluth Trading Company's
wrongful conduct, Duluth Trading Company
has
and will continue to wrongfully
profit.
40.
As a direct
and
proximate result of Duluth Trading
Company's
wrongful conduct,
Mr. Henley has suffered substantial
injury
in fact. In addition,
Duluth Trading
Company's unlawful conduct has and continues to cause irreparable
injury to Mr.
Henley and
his
reputation
and
goodwill.
Unless
the
improper conduct
is enjoined,
Duluth
Trading
Company will cause further irreparable
injury for
which
aw
an injunction restraining
Duluth
Trading
Company,
its
officers,
agents,
employees,
and all persons
acting
in concert
with
it,
from engaging in further such unlawful conduct.
entitled to restitutionary
recovery
and
Mr.
Henley hasno adequate remedy at
41. Mr. Henley is entitled tc
42. Mr. Henley is further
disgorgement
from
Duluth Trading Company
FOURTH
CL;
JM
FOR
RELIEF
Violation ofCalifornia Statutory Bight ofPublicity, Cal. Civ. Code 3344)
43. Mr. Henley incorporates
b>
reference Paragraphs 1through 42 above as
though fully set forth herein.
44. Without Mr.
Henley's
consbnt, Duluth Trading Company has
knowingly caused the Advertisement,
wiich prominently
contains Mr. Henley's
COMPLAINT
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Loeb
& Loeb
ALimitedLiability Partnership
Including
Professional
Corporations
name, to be created andprominently
this judicial district.
45. Suchuse of Mr. Henley's
purposes of advertising, selling and
Company's
products, merchandise,
g
46. DuluthTrading Company'
Civil Code Section 3344, since such
47. There was, and is, a direct
ofMr. Henley's name and the commercial
ofDuluthTradingCompany and its
48. As a proximateresult of th|e
has been and will
continue to
be
harrm
49. The use of Mr. Henley's
Henley endorsed theDuluthTrading
goods and services.
50. As a proximate result
Henleyhas sufferedactual damages in
51. Pursuant to California Civil
entitled to disgorgement
of
Duluth
Tradb
Advertisement, resulting fromthe
amount to be proven at trial.
52. Duluth Trade Company's
oppressive; it acted in conscious disreg;
Mr. Henley to unjust hardship. Duluth
required to obtain approval for its use
Henley seeks
an
award
of
punitive
damaj
for
Duluth
Trading Company's wrong
in th e future.
^k
displayed in
interstate
commerce,
including in
Dy
DuluthTradingCompany was for the
solfciting the
purchase
ofDuluth Trading
and
services,
s
conduct
is in direct violation of California
were without
the consent ofMr.
Henley,
connection between the use andexploitation
purposes associated with the promotion
ucts, merchandise, goods and services,
misappropriation ofhis
name,
Mr. Henley
SOcds
ac s
led
n ime
in theAdvertisements impliesthatMr.
C4mpany
and/or its
products,
merchandise,
o fD i l u t h
Trading Company's actions, Mr.
amount to be proven at trial.
Code Section3344,Mr. Henley is also
g Company's profits from the
unauthorized exploitation of his name, inan
qonductwaswillful, malicious and
ofMr. Henly's rights thereby subjecting
rading Company well knew that it was
Henley's name. Accordingly,Mr.
ges in an amount to be determinedat trial,
g andto deterit
from
similar wrongdoing
;ard
o fMr.
xkin i
10
COMPLAINT
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Loeb & Loeb
ALimitedLiability Partnership
Including Professional
Corporations
Q
^^
53. Pursuant to California Civtl
to recoverhis attorneys' fees in pursuir
F IFTH
(Common La^
54. Mr. Henley incorporates
though fully set forth herein.
55. By using his name in
highly successful single, Take It
Advertisement.
56. Duluth Trading Company
Advertisement in conjunction with the
single, Take It Easy, was in interstate
sales of its clothing and advance Duluth
57. On
information and
belief,
by its wrongful conduct and activities.
58 .
On
information and belief.
Mr. Henley's namewas knowing and
it was a violation
of
his rights.
59. Mr. Henley is entitled to
damages, including attorneys' fees, he
and advantages obtained by Duluth
as alleged
above,
and an awardofp
damages, gains, profits, andadvantages
P R A Y E R
WHEREFORE, Mr. Henley resp
againstDefendantDuluthTrading
a. For temporary, preliminaijy
Duluth Trading Company, prohibitin
ilCode Section
3344,
Mr.
Henley
is
entitled
g this action.
CLAIM
FOR
RELff iF
Right
of
Publicity)
b^
reference Paragraphs
1
through 53 above
as
conjunction with the title of the Eagles' debut,
, Mr. Henley is clearly identified in the
a:y
's use of Mr. Henley's name in the
title of the Eagles' debut, highly successful
commerce and done specifically to increase
Trading Company's other interests.
Duluth
Trading Company
has or will profit
Duluth Trading Company's decision to use
mlalicious,
and done
with
clear knowledge that
-ecover
from Duluth Trading Company the
has and will
sustain,
and any
gains, profits,
ingCompany asa result of its infringement
damages. At present, the amount of such
cannot fully be ascertained by
Mr.
Henley.
FO R REL IEF
>;ctfully
requests that this Court grant relief
as
fol lows:
and permanent injunctive relief against
Duluth Trading Company, its agents, or
Tra i in
junit:
ve
Company
ig
11
COMPLAINT
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Loeb & Loeb
A Limited
Liability
Partnership
Including
Professional
Corporations
^
anyone working for, in concert with oi
advertising for sale any merchandise
trademark.
b.
That Duluth Trading
Corppany
sustained in consequence
of
Duluth Tra'din
c. That Duluth Trading
Com|pany
Duluth Trading Company as a
d.
That Mr. Henley recover
e.
That
Mr.
Henley recove|r
Company.
f. That Mr. Henley have
just and proper.
Dated: October 8, 2014
onbehalfof
Duluth Trading Company from
contains
Mr. Henley's
name
or
registered
ha t
consequence
his
pay Mr. Henley the damages he has
ing Company's conduct.
pay Mr.
Henley
all profits obtained by
of Duluth TradingCompany's conduct,
costs and reasonable attorneys' fees,
punitive
damages from Duluth
Trading
sue l
other
and
further
relief
as the Court deems
LOEB
LOEB
LLP
THOMAS
P. JIRGAL
MELANIE J. HOWARD
Ey::
12
anie 'J . Howard
Attorneys for Plaintiff
Don Henley
COMPLAINT
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2
3
4
5
6
7
8
9
2
3
4
5
6
7
8
9
2
3
4
5
6
7
8
Loeb
& Loeb
A LimitedLiability Partnership
Including Professional
Corporations
Mr. Henley hereby demands a
Dated: October 8, 2014
k
JURY
DEMAND
trial byjuryonall issues so
triable.
tOEB &LOEB LLP
'HOMAS P. JIRGAL
I/ELANIE J. HOWARD J
Attorneys for Plaintiff
Don Henley
13
COMPLAINT
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A
A
8/11/2019 Don Henley v. Duluth Holdings - Don a Henley t-shirts.pdf
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Int CI.:
9
Prior U.S.
Cls.: 21, 23, 26, 36 and 38
Uni ted States Paten t and Trademark
Reg.
No . 2,337,742
Office
Registered Apr.
4, 2000
T R A D E M A R K
PR INC IPAL
REGISTER
D ON HENLEY
HENLEY, DON
(UNITED
STATES CITIZEN)
C/O AZOFF ENTERTA INMENT
3500
W
OL IVE AVENUESU ITE 60 0
BURBANK,
CA 91505
FOR: SER IES
O F M USICAL
SOUND RE
CORDINGS;
AND
A SERIES OF
PRE-RECORD
ED
COMPACT DISCS,
PRE-RECORDED
AUDIO CASSETTES,
PRE-RECORDED VIDEO
TAPES, AND
PRE-RECORDED AUDIO/
VISUAL
DISCS
ALL
FEATURING
MUSIC,
IN
CIASS
9 (U.S. CLS. 21, 23, 26, 36 AND 38).
FIRST
USE
8-19-1982; IN COMMERCE
9-1982.
I5ER. NO. 75-576,475, FILED
10-27-1998.
ANTHONY MERCALDI ,
EXAMINING
ATTOR-
l ^EY
8/11/2019 Don Henley v. Duluth Holdings - Don a Henley t-shirts.pdf
16/23
Int. CL:41
Prior U.S. Cls.: 100,101 and 107
United States Patent
and
Trademark
Reg. No. 2,359,466
Off ice Registered Jane
20,2000
SERVICE MARK
PRINCIPAL
REGISTER
DON
HENLEY
HENLEY, DON UNITED
STATES
CITIZEN)
C/O AZOFF ENTERTAINMENT
3500W. OLIVE AVENUE, SUITE600
BURBANK, CA 91505
FOR: ENTERTAINMENT SERVICES
IN
THE
NA
TURE
OF LIVE
MUSICAL
PERFORMANCES, IN
CLASS 41
U.S.
CLS. 100,101
AND107).
FIRST
THENAME
mo
RECORD
USE 0-0-1981; IN
COMMERCE
0-0-1981.
DON HENLEY IDENTIFIES A
UV-
WHOSE CONSENT IS OF
NDIVIDUAL
SER. NO. 75-576,421, FILED 10-27-1998.
ANTHOl iY MERCALDL EXAMINING
ATTORNEY
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^B
^
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OFFER NOTES:
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2014 DuluthTrading Company
170 Countryside Drive, Belleville, Wl 53508
Siol
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UNITED STATES DISTRICT COURT, CENTRAL DISTRICT OF CALIFORNIA
CIVIL COVER
SHEET
I
(a)
PLAINTIFFS (
Check
box ifyou are
representing
yourself )
Don Henley, an individual
DE FENDANTS
(
Check box if you
are
representing yourself
)
Duluth Holdings Inc., d/b/aDuluth
Trading Company,
a
W sconsin corporation ''
(b) County of
Residence
of First Listed Plaintiff
Dallas,
TX
EXCEPT
INUS PLAINTIFF CASES)
(c) Attorneys Firm Name, Address and Telephone Number) If you are
representing yourself, provide th e
same
information.
LOEB &
LOEB LLP
Thomas P. Jirgal (202637); Melanie
Howard
(218895)
10100 Santa Monica Boulevard, Suite 2200
Los Angeles, California 90067
Phone: 310-282-2000; Facsimile: 310-282-2200
nty of Residence of First Listed
Defendant
Dane, Wl
/ S. PLAINTIFFCASES
ONL Y
Attorneys Firm
Name, Address and
Telephone
Number) If you
are
representing
yourself,
provide
the
same
information.
II.
BASIS OFJURISDICTION (Place anX in one box only.)
III.
CITIZENSHIP
OF PRINCIPAL
PARTIES-For
Diversity Cases
Only
an X inone box for plaintiffand one for defendant)
i*
c.o.o II II Incorporated orPrincipal Place If Ef
State LJ1 D1 of Business
in this State D